[Krupali is a student at Gujarat National Law University.] On 15 January 2026, the Apex Court in Tiger Global International II Holdings v. AAR (Tiger Global) denied treaty relief under the India-Mauritius DTAA, relying on the doctrine of substance over form. Eleven months before then, in SC Lowy PI (LUX) SARL v. ACIT (SC Lowy), the Income Tax Appellate Tribunal, Delhi delivered India’s first judicial application of the principal purpose test (PPT). This was followed by the In

The RBI already has everything it needs for the purpose. It has a standalone control test; policy authority sitting with DPIIT; and administrative authority over the rules. All it needs is for one specific lacuna to be filled, namely, who takes charge in case of conflicting or inconsistent sector-specific interpretations of the control tests.

The PPO framework has been extensively discussed by practitioners and scholars, attracting criticism ranging from inadequate opportunity to be heard, to enforcement problems arising from the provisional nature of these orders.